WY | YU STATE OF FLORIDA rallED DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, IVissaty 0 | ADMIRIS [RAI TY Petitioner, O0-OU1\9 HEARINGS vs. CASE NO.: 98-17273 ASHFAQ AHMED, Respondent. _/ | ADMINISTRATIVE COMPLAINT | 8 Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Physical Therapy against ASHFAQ AHMED, hereinafter referred toas “Respondent,” and alleges: | 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of Physical Therapy pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and-Chapter 486, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative, and * prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 00 JAN 25 PM 3:33 U | U 2. Respondent is, and has been at all times material hereto, a | licensed Physical Therapist in the state of Florida, having been issued license number PT 0003227. 3. Respondent’s last known address is P.O. Box 1493, Goddord Road, Taylor Michigan, 48180-5893. 4. During the period from da or about March, 1987, to on or about October, 1995, the Respondent conspired to defraud Medicare and Medicaid by offering to pay kickbacks in return for the referral of patients for physical therapy for which payment was made in whole or in part by Medicare and ¥ Medicaid. 5. On or about June 25, 1998, the Respondent was sentenced to a term of 21 months in‘prison, to comnfence 60 days trom the aforementioned date, for conspiracy to defraud the United States by United States District Court, Eastern District of Michigan. — 6. - On or about May 10, 1981, the Respondent made application to become a Registered Physical Therapist in the State of Florida. 7. On this application, the Respondent stated that he had received his Physical Therapy education and graduated from the University of Toronto in Ontario, Canada in 1968. | U | UY 8. | Documents show that the Respondent, in fact, received his Physical Therapy degree from the University of Karachi, India in 1967. COUNT I 9. Petitioner realleges and incorporates by reference the allegations contained in paragraphs one (1) through eight (8) above. 10. Based on the foregoing, the Respondent has violated Section 486.125(1)(b), Florida Statutes, by having committed fraud in the practice of physical therapy or deceit in obtaining a license as a physical therapist or as a physical therapist assistant. | e COUNT II 11. Petitioner realleges and incorporates by reference the allegations contained in paragraphs one (1) through eight (8) above. 12. Based on the foregoing, the Respondent has violated Section 486. 125(1)(¢), Florida Statutes, by being convicted of a crime directly relating to the practice of physical therapy. WHEREFORE, Petitioner respectfully requests that the Board of Physical Therapy enter an order imposing one or more of the following penalties: revocation or suspension of Respondent’s license, restriction of Respondent's practice, imposition of an administrative fine, issuance of a reprimand, placement of Respondent's license on probation for a period of time and subject to terms and/or conditions, and/or other relief which the Board deems appropriate. SIGNED this TWH day of nebo , 1999. Robert G. Brooks, M.D. | Secretary, Department of Health ancy M. Snurkowski, Chief Attorney General Counsel’s Office-MQA Practitioner Regulation-Legal COUNSEL FOR PETITIONER: Shannon R. Fleming, Senior Attorney Florida Bar Number 0166677 seg gas ' Agency for Health Care Administration oo riLeED _ Practitioner Regulation-Legal | DEPARTMENT OF HEALTH SRF/sgw 10/28/99 EPUTY CLERK Post Office Box 14229 | CLERK Q. Dun Tallahassee, Florida 32317-4229 G-45 Phone: (850) 487-9694 | oare_/I[S

Docket for Case No: 00-000415